Legal Opinion
National Commodity & Barter Ass'n/National Commodity Exchange v. United States
District Court, D. Colorado
Decided October 22, 1993No. Civ. A. No. 89-M-1912PublishedCited by 4 opinions
1Opinion of the Court
MEMORANDUM OPINION AND ORDER
MATSCH, District Judge.
The National Commodity and Barter Assoeiation/National Commodity Exchange (NCBA/NCE) brings this suit against the United States for a refund of penalties assessed under I.R.C. § 6698 for failing to file partnership returns for the years 1979-1988 and I.R.C. § 6700 for promoting an abusive tax shelter. This court has jurisdiction over the matter pursuant to I.R.C. § 7422 and 28 U.S.C. § 1346(a)(1). A trial to the court was held November 16-19, 1992 and December 30, 1992. Extensive post-trial briefs were filed. This memorandum opinion…
2Cases cited45 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Virginia State Board of Pharmacy v. Virginia Citizens Consumer Council, Inc.Supreme Court of the United States · 1976
- Brandenburg v. OhioSupreme Court of the United States · 1969
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Commissioner v. TowerSupreme Court of the United States · 1946
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3Cited by4 opinions
- United States v. SchiffDistrict Court, D. Nevada · 2003
- Vanderschraaf v. CommissionerUnited States Tax Court · 1997
- Elite Oil Field Enterprises, Inc. v. United StatesDistrict Court, D. Colorado · 2021
- ncba/nce v. United StatesDistrict Court, D. Colorado · 1993